A&B Abstract The CFPB’s statutory authority to issue a recent request for information (RFI) regarding employer-driven debt is in doubt, which may affect the utility of any comments submitted in response to its request. Background On June 9, the CFPB issued an RFI Regarding Employer-Driven Debt. The RFI seeks comment on several areas of inquiry relating to “employer-driven debts,” including prevalence, pricing and other terms of the obligations, disclosures, dispute resolution, and … [Continue reading] about Did the CFPB Have Authority to Issue its RFI Regarding Employer-Driven Debt?
A&B Abstract The second observance of the Juneteenth National Independence Day (Juneteenth) holiday is Monday, June 20, 2022. President Biden signed legislation making Juneteenth National Independence Day a federal national holiday last year. … [Continue reading] about Second Juneteenth Holiday Raises Tricky Compliance Issues
A&B Abstract: On May 12, 2022, the Maryland Office of the Commissioner of Financial Regulation (the “OCFR”) issued an Industry Advisory (the “Advisory”) “put[ting] [the] industry on notice” of the recent decision issued by the 4th Circuit … [Continue reading] about Maryland Regulator Puts Lenders and Servicers on Notice Regarding the Assessment of So-Called “Convenience Fees”
On May 26, 2022 the Consumer Financial Protection Bureau released a Consumer Financial Protection Circular stating that creditors utilizing algorithmic tools in credit making decisions must provide “statements of specific reasons to applicants … [Continue reading] about CFPB Continues Scrutiny of Algorithmic Technology
In a recent Financial Services & Products Advisory, Partners Nanci Weissgold and Anoush Garakani evaluate the CFPB's recent "junk fees" initiative and its potential effect on mortgage servicing fee structures. The advisory can be accessed here. … [Continue reading] about Client Advisory: One Person’s Junk Fee Is Another’s Treasure